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TECHNICAL STATEMENT K284CW WINCHESTER, 276D SILVER STATE BROADCASTING LLC FCC FORM 349 DECEMBER 2019

This Technical Statement is in support of a new construction permit for K284CW, facility ID #203222, to address a noise complaint to pending license application, BLFT-

20190605ACH. Silver State Broadcasting is proposing to amend the channel from 284 to

276, the antenna from directional to nondirectional, and the from

10 to 250 Watts. The antenna will be mounted at 15 meters Above Ground Level, with a

Center of Radiation at 535 meters Above Mean Sea Level.

Figure 1 shows a channel interference study conducted from the proposed site for the K284CW translator. The only pertinent records for further study are:

1) KCYE Boulder , Nevada 274C License

2) KISF , Nevada 278C License

3) DKQLS-LP Las Vegas, Nevada 276L1 CP

The proposed site is located within the protected contours of 2nd adjacent stations

KCYE Boulder City, Nevada on channel 274C and KISF Las Vegas, Nevada on channel

278C. At the proposed transmitter site, the predicted F(50-50) field strength of KCYE is

97.0 dBμ and KISF is 101.6 dBμ. The worst-case predicted interfering contour F(50-10) generated by the proposed facility to either KCYE or KISF would be at an additional 40 dBμ above the 97.0 dBμ received from KCYE at a signal strength of 137.0 dBμ. This 137.0 dBμ interference contour F(50-10) travels a maximum distance of 15.6 meters from the transmitting antenna. Figure 2 shows that there is no population within 200 meters of the transmission site. The applicant, Silver State Broadcasting LLC, Inc., respectfully states that this application meets the requirements of C.F.R. 74.1204(d) of the Commission's rules based on the fact that there is no population within the area of predicted interference. Figure 3 shows that KQLS-LP loss their license on November 19, 2019.

Figure 4 shows the 60 dBμ contours of the proposed facility,in red, and the current licensed facility seeking to be modified by this application, in blue, overlap.

The proposed operation of K284CW translator will operate as a fill-in for KBET(AM)

Winchester, Nevada, facility ID #136292. Figure 5 shows that the 60 dBμ contour F(50,50) of the K284CW translator is fully within the 2 mV/m contour of KBET(AM).

This modification will continue to use the same antenna mounted on the STL receive pole that was previously approved and licensed. This pole is grounded and is 11 meters away from the middle directional AM tower near the equipment building. This pole has always been present for KBET(AM) STL purposes and was constructed during 2007, prior to earliest proof for KBET. It is technically improbable that any technical parameter could or would change as a consequence of this minor installation.

It was concluded that the proposed operation of K284CW translator in Winchester,

Nevada on 276D will not cause any harmful interference to any existing stations and will be in full compliance with the Commission's rules.